PACIFIC TRANSPORT COMPANY v. C. I. R.

Nos. 71-1754 to 71-1764, 71-1810.

483 F.2d 209 (1973)

PACIFIC TRANSPORT COMPANY and Subsidiaries, Appellee-Cross-Appellant, v. COMMISSIONER OF INTERNAL REVENUE, Appellant-Cross-Appellee. PACIFIC ATLANTIC STEAMSHIP COMPANY, Appellee-Cross-Appellant, v. COMMISSIONER OF INTERNAL REVENUE, Appellant-Cross-Appellee (two cases). STATES STEAMSHIP COMPANY, etc., Appellee-Cross-Appellant, v. COMMISSIONER OF INTERNAL REVENUE, Appellant-Cross-Appellee (two cases). STATES STEAMSHIP COMPANY, Appellee-Cross-Appellant, v. COMMISSIONER OF INTERNAL REVENUE, Appellant-Cross-Appellee. PORTLAND STEVEDORING COMPANY, Appellee-Cross-Appellant, v. COMMISSIONER OF INTERNAL REVENUE, Appellant-Cross-Appellee (two cases). PACIFIC TRANSPORT LINES, INC., Appellee-Cross-Appellant, v. COMMISSIONER OF INTERNAL REVENUE, Appellant-Cross-Appellee. CALIFORNIA EASTERN LINES, INC., Appellee-Cross-Appellant, v. COMMISSIONER OF INTERNAL REVENUE, Appellant-Cross-Appellee (two cases). PACIFIC TRANSPORT COMPANY, and Subsidiaries, et al., Appellants-Cross-Appellees, v. COMMISSIONER OF INTERNAL REVENUE, Appellee-Cross-Appellant.

United States Court of Appeals, Ninth Circuit.

Rehearing Denied September 10, 1973.


Attorney(s) appearing for the Case

Janet R. Spragens, Atty. (argued), Fred B. Ugast, Acting Asst. Atty. Gen., Scott P. Crampton, Acting Asst. Atty. Gen., Tax Div., Dept of Justice, K. Martin Worthy, IRS Chief Counsel, Meyer T. Rothwacks, Ernest J. Brown, Tax Div., Dept. of Justice, Washington, D. C., for appellant and appellant and appellee in No. 71-1810.

Valentine Brookes (argued), Richard A. Wilson, of Brookes, Maier & Wilson, San Francisco, Cal., for the appellees and appellants in No. 71-1810.

Before ELY and KILKENNY, Circuit Judges, and SKOPIL, District Judge.


OPINION

PER CURIAM:

These appeals and cross-appeals are prosecuted from decisions of the tax court involving corporate income taxes for the tax year 1958 and certain tax periods in 1957. The taxpayers consist of a group of affiliated steamship companies. The deficiencies arise from the reduction of a net operating loss claimed by the group in 1959, a year not in issue, and carried back to taxable periods in 1957 and 1958, two open years.

Factual...

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